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Home My WebLink About01-06597 - I ~ 1l&.' " ,~' '", '--iIl!~="1\ijiJ~~';if~.h- ~ . 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Ut~lit~es Inc. Plaintiff Civil Action - In Law VB No. {5 (- &617 ~ Sondra Peel Defendant ARBITRATION \ \ \, \" \"" \"'" \ \ \, \ \ \" \ \ \ \ \ \ \ \ \ COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/ (800) 990-910 'li! '~-'.~'~ ~-~""',~, ~ ~^ hli_ -", '" ll1I.lJ~m~.i9:t1~ . .' 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utillties Inc. Plaintiff Civil Action - In Law vs No. Sondra Peel Defendant ARBITRATION ,\ \ \ \ \ \ \, \ \ \ \ \ \ \ \ \ \ \ \, \, \ \ \ \ \ \ \ \ \, \ \ COMPLAINT 1. This is an action by Plaintiff, UGI utilities Inc. to recover damages from Defendant arising out of a debt Defendant owes to Plaintiff by virtue of utility service. 2. UGI Utilities Inc. is a Pennsylvania corporation duly organized and existing and licensed to do business as a public utility under the laws of the Commonwealth of Pennsylvania with a principal place of business at 225 Morgantown Road, Reading, PA 19612-3009. 3. Defendant, Sondra Peel, is an adult individual residing at 436 N. Pitt Street, Carlisle, PA 17013. . ~ 1-' , '"'"'"~ ..1.....;..,-,,,,",,",,,, - '.~ ylo-'-" '--~!i&k<i-' . . COUNT 1 UGI Utillties Inc. vs. Sondra Peel 4. At all time relevant hereto, Plaintiff was engaged in the business of producing, furnishing, supplying and distributing utility service to persons and businesses who requested utility service in accordance with the Rate Schedules and General Rules and Regulations of Plaintiff's Tariff presently on file with the Public Utility Commission. 5. plaintiff supplied utility service to Sondra Peel. 6. At the present time, Defendant account is in default and has outstanding balance due and owing Plaintiff as reflected on the attached Statement of Accounts which contains information taken directly from Plaintiff's original business records, and which includes the unpaid balance and all appropriate debits, and credits, and late charges and which is attached hereto and marked Exhibit "A", incorporated herein by reference and made a part hereof. 7. The utility service which was provided by the Plaintiff to the Defendant aforesaid, was received, accepted, and utilized for the benefit of said Defendant. ~; I, "--'- '""~,_. u ~! tl!itti:jf:@iMi~';(!'_ . " 1537U2 8. Defendant is in default of his/her obligation, having failed to make the payments as they became due. 9. Plaintiff made demand on Defendant to repay the sums then due and owing to Plaintiff, but Defendant has refused and continues to refuse to pay Plaintiff. 10. Despite demands upon Defendant for payment by the Plaintiff, Defendant has failed and refused to pay Plaintiff the balance due and owing on said account(s). 11. Defendant has been unjustly enriched by accepting service without full payment. WHEREFORE, there is now due and owing from the Defendant to the plaintiff the following sums for which Plaintiff demands judgment against the Defendant: Amount Past Due: Court Costs: Service Costs: TOTAL $ 1104.41 $ 45.50 $ 100.00 $ 1249.91 Respectfully submitted, DATED: November 14, 2001 Associates 18938 " ------ ,"",' ,. < ~ "...:..;. ,j'ilK" -'lil-= -"O--""'-'-im!4:~1 c,c . VERIFICATION I, Aprille Beasley, an employee ofUGI Utilities, Inc., being authorized to do so, verify that the statements made in the foregoing pleadings are true and correct to the best of my knowledge, information and belief. To the extent any averments therein are inconsistent in fact, I have been unable, after reasonable investigation, to ascertain which are true, but I have knowledge or information sufficient to form a beliefthat one of them is true. This statement is made subject to the penalties of 18 P.A. C.S. Section 4904, relating to unsworn falsification to authorities. UGI Utilities, Inc. Dated: It I HI 0/ BY: 4 ~-' L. ^~~ ~_ ",-,,-, ~= J-- ~ - ~ ..:,.., ""; , --~. ~"~ ";',*.-*,.&.i--,_~"'- . " 1537U2 STATEMENT OF ACCOUNT Sondra Peel established the following accounts with UGI Utilities Inc. with the following balances and charges: Account Number / Service Address Acct Type Service to: Balance ================================================================================ 213-769-4822-03 436 N. Pitt Street Carlisle, PA 17013 G / / $1104.41 Total Delinquent Balance: $1104.41 EXHIBIT A ~~"i"J""~~'il!liL0';!WX!i~&m~,".ii;W~~"";1M.;Y6~"'''"'''''~"_'iiH;I"""",,j-i",:",";&:,;';<,Ni"","'''''i,b'1~f,c'_'\'-','Tik!lli!~;i.,~~ill!(_" "" '"'Iii.-J,;;~,~:; -, . ~ 'c;)~ -l ?>-C "- , ~ r- --.) J (j C',) 0 -" (= -Tl 0 ?--' .~"" :'::,.., Z :..J -J vCI:'! c;~ '-.N nlr,--' -,':"'-n r ~ Z::;' , ' "f::: 0..J C'j ~~i l'.) 'oT 0"' ;:3~I: ~r r.: C) :r>' ~~t~~ o-t 2,-:, ::1: Zc )>c: tsfTl :z --l , ) - ,., ::;:1 ~ 'lJ 'G! if' (...> -< <Y @ ~2 ~S ,""^,, '" ,--~ ~~- . ~~- "~~~,~> , .=J~~_< ., ~,.~,~.. n">, _,",~_ " . -~ -, --" ,'~~,,~--,~ " =. ,_.~ '" ~ < ~ ~- L^"~' _..J _ ~~ 1 b:.ll''''fi'''-''''''''',"i.,,,~~'!'-" SHERIFF'S RETURN - REGULAR CASE NO: 2001-06597 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS PEEL SONDRA JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEEL SONDRA the DEFENDANT , at 1709:00 HOURS, on the 30th day of November, 2001 at 98 GROVE ROAD CARLISLE, PA 17013 by handing to MISTY SNYDER, ROOMMATE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.15 .00 10.00 .00 35.15 r-~/ff~ R. Thomas Kline 12/03/2001 KRZYWICKI & ASSOC Sworn and Subscribed to before By: ~~ D puty Sheriff me this 81!:: day of JJ)ln"'~UJ / .:J1HJ1 A.D. ~{l~'~" rothonotary' ,~ .'. ~ Curtis R. Long Prothonotary TO: Sondra Peel 436 N. Pitt Street Carlisle, PA 17013 - ,I_J'; '" ,_ ~~'~~, ~ i- j ~ ,_ -, "~ ~ -. 1537U2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUmberland County Courthouse * Carlisle, PA 17013 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilitles Inc. Plaintiff civil Action - In Law vs Sondra Peel Defendant No. 01-6597 CV \ \ \ \ \ \ \'" \. \ \, \ \, \ \, \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ ARBITRATION NOTICE Pur~uant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. (XX) ( ) ( ) ( ) ( ) ( ) ( ) Curtis R. Long Prothonotary Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE"CALL ATTORNEY FOR THE FILING PARTY: Anthony P. Krzywicki Krzywicki and Associates 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney I.D. No.23754 "~ .~' -~~~ .... I', ~~ ~ -j '-"'-'-1'-"'~-"~ 'L, I~~,;,,_ 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllities Inc. Plaintiff civil Action - In Law vs No. 01-6597 CV Sondra Peel Defendant ARBITRATION '" \ \ \'" \ \ \"""" \ \ \ \ \ \ \ \ \ \ \ \'" \ PRAECIPE FOR JUDGMENT AGAINST DEFENDANT FOR FAILURE TO PLEAD To the Prothonotary: COUNT 1 UGI Utilitles Inc. vs. Sondra Peel Kindly enter default judgment in favor of Plaintiff, UGI utilities Inc. and against Defendant, Sondra Peel for failure to plead to Plaintiff's Complaint as follows: Amount Past Due: Court Costs: Service Costs: TOTAL $ 1104.41 $ 45.50 $ 100.00 $ 1249.91 together with interest thereon from the date of judgment forward and all costs of this action. "'" -.; - -~-"~~ ..... '0' . ~ _-'_,C c_''- ".,' '.~ ., iL" '!!ii,': ~'xf.. 1537U2 I hereby certify to the best of my knowledge and belief as follows; 1. The true and correct address of the Plaintiff, UGI Utilities Inc., is 225 Morgantown Road, Reading, PA 19612-3009. 2. The true and correct address of the Defendant, Sondra Peel, is 436 N. pitt Street, Carlisle, Cumberland County, PA 17013. DATED: March 5, 2002 Krzywicki ~ " ,,- . j ~ - ,","-"",,:,~d':;~' ,,,,,'.,;.u,,,-~. -~'It"t~~M<~,' ~~~ SHERIFF'S RETURN - REGULAR CASE NO:, 2001-06597 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UGI UTILITIES INC VS PEEL SaNDRA JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PEEL SaNDRA the DEFENDANT , at 1709:00 HOURS, on the 30th day of November, 2001 at 98 GROVE ROAD CARLISLE, PA 17013 by handing to MISTY SNYDER, ROOMMATE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 7.15 .00 10.00 .00 35.15 ~,;";. ..I~//~< .,I' ,{.",.",.,.-/ ,..,. ~ ~~~- -7' ~."..<:A' R. Thomas Kline 12/03/2001 KRZYWICKI & ASSOC BY:~~ , D puty Sheriff , / , / '_/ Sworn and Subscribed to before me this day of ~ -::.. . -' . Prothonotary ~\.,\. "L- \S o , " '''''-''"'''''nf-' ),.-. _~,;""o;~ 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utlllties Inc. Plaintiff Civil Action - In Law vs No. 01-6597 CV Sondra Peel Defendant ARBITRATION \ \ \ \ \ \ \ \ \ \ \"'" \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ NOTICE TO: Sondra Peel 436 N. Pitt Street Carlisle, PA 17013 Date: January 25, 2002 You are in default because you have failed to enter a written appearance personally or by an attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 (717) 249-3166/ (800) 990-9108 Krzywicki and Associates By: lsl Anthony P. KrzYWlckl 49 North Sugan Road P.O. Box 505 New Hope, PA 18938 800-296-2103 Attorney for Plaintiff Attorney I.D. 23754 , r U.S. POSTA SERVICE CERTlFICA OF MAILING MAY BE USED FOR DOMI!STlC AND INTERNA nONAl MAIL. DOES NOT PROVloe FOR INSUAANCE-P.OSTMASTER R8C8I' PS Form 3817. Mar. 1989 . :~L=,. .".-.1 ~'-,,,,,- JlI bJ. ~oI 0 (J r)P' aiY~;1 . q ( 0. Oll~ UJ'}>>' " Id ,I " I Iii lIJ Cl I I.n ~ r-; 0 0 .... <Ji ! ill -'- ~ - . r- ;-.~-I~~" ,..." -'-~iJiitW"i; - I' -,.J__ . . I , -- "0 '~""_'-Vi'.;!- 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utllities Inc. Plaintiff Civil Action - In Law vs No. 01-6597 CV Sondra Peel Defendant ARBITRATION \ \ \'" \ \ \ \ \ \" \ \, \, \ \ \"'" \ \ \ \ \"" The undersigned hereby certifies that written notice of intention to file a praecipe for entry of judgment by default against the defendant, Sondra Peel, in this matter was mailed to the defendant after the default occurred and at least ten days prior to the filing of the praecipe for entry of judgment pursuant to Pa. R.C.P. 237.1. True and correct copies of that notice is attached hereto and made a part of this certification. DATED: March 5, 2002 l / =------- Krzywicki 18938 .. -~ - 11....... ;~ '.~'~ ;';i/I\I'~-<liI;~';,'_","",-,,,, . . 1537U2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania UGI Utilltie$ Inc. Plaintiff Civil Action - In Law vs No. 01-6597 CV Sondra Peel Defendant ARBITRATION "\'" \, \" \ \ \" \"" \""""""" AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY ss. COUNTY OF HUNTERDON I, Anthony P. Krzywicki, being duly sworn according to law, deposes and state that I am a representative of UGI Utilities Inc., 225 Morgantown Road, Reading, PA 19612-3009, Plaintiff herein, and as such state the following: 1. The defendant, Sondra Peel, is not, to my knowledge, in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' civil Relief Act of 1940, as amended. 2. The defendant, Sondra Peel,is more than 18 years of age and currently resides at 436 N. pitt Street, Carlisle, PA 17013. 3. I have ascertained the above information by personal investigation and make this affidavit wi due authority. l ------- MICHELLE py. IT I'OT ARY PUBLIC OF NEW JERSEY ^ Y COMMISSION EXPIRES JULY 9. 2002 JC"~' -""" f' I', '~;;";";;_~~'~~A'i\80,,-,~i1<'''"''''itr,uc;:'i';:i;.;;,-ihM,,"j,~h@df''''''!N'~:"<>ir""NWr;;;:~ffiil!lll~..tfil~~'" ~""'"'-~'iW'lii#;\/ij<~~ -i:folS~IlWi"'ln~ - ". ,~~ - dBllt;, . 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